A controlled group of corporations must apportion tax benefits (e.g.,Sec.179 expense limitation)among the group members as if only one corporation existed.

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This is true. A controlled group of corporations is treated as one group for tax purposes and must apportion tax benefits among the group members as if only one corporation existed. This is done to prevent corporations from manipulating the tax benefits through inter-company transactions.

A Controlled Group of Corporations Must Apportion Tax Benefits (E